Search

Telecom - Staff Letter addressed to the Distribution List

Gatineau, 3 March 2025

ABRIDGED

References: 8740-B2-202302248, 8740-A53-202302256, 8740-M59-202302264, 8740-T66-202303494, 8740-T69-202303502, 8740-S22-202302230

BY EMAIL

Distribution list

Subject: Follow-up to Telecom Notice of Consultation CRTC 2023-56 – Notice of Hearing – Review of the wholesale high-speed access service framework – Supplemental Requests for Information

As part of the proceeding initiated by Notice of hearing – Review of the wholesale high-speed access service framework, Telecom Notice of Consultation 2023-56, dated 8 March 2023 (NoC 2023-56), the Commission directed wholesale high-speed access (HSA) service providers to file, amongst other things, proposed tariffs and associated cost studies using the Phase II costing methodology, with supporting rationale, for fibre-to-the-premises (FTTP) facilities over aggregated wholesale HSA services.

Attached to this letter are further requests for information (RFIs) to Bell Canada, Bell Aliant, Bell MTS, TELUS Communications Inc. (TCI), Saskatchewan Telecommunications (SaskTel), Competitive Network Operators of Canada (CNOC), TekSavvy Solutions Inc. (TekSavvy), and other competitors. Responses to the RFIs are due no later than 31 March 2025.

As set out in section 39 of the Telecommunications ActFootnote 1 and in Broadcasting and Telecom Information Bulletin CRTC 2010-961Footnote 2, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Parties and interested persons may request the public disclosure of information that has been designated confidential in responses to the attached RFIs, setting out in each case the reasons for disclosure. These disclosure requests must be filed with the Commission and served on the entities to whom they are addressed by 7 April 2025. Responses to those disclosure requests may then be filed with the Commission no later than 15 April 2025.

All documents filed and served must be received, not merely sent, by the date provided. Parties are to send an electronic copy of all documents to Commission staff copied on this letter.

The Commission requires the responding documentation to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover Page” located on the Commission’s website.

An abridged copy of this letter and all related correspondence will be added to the public record of the proceeding.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunications Sector

c.c.: Abderrahman El Fatihi, CRTC, 819-953-3662, AbderRahman.ElFatihi@crtc.gc.ca
Stais Armstrong, CRTC, 819-775-0401, Stacey.Armstrong@crtc.gc.ca

Attach. (4)

Distribution List

Requests for Information (RFI)

Bell Aliant, Bell Canada, Bell MTS, SaskTel, TELUS AB/BC, TELUS Quebec

  1. Refer to the General Tariff (GT) items which details the exchange descriptions and their associated rate band classificationFootnote 3. Complete the Excel worksheet in Attachment 1 for each province by rate band, by providing the requested data for each of the historical years 2008-2024 and forecast year 2025. The data must reflect the actual construction mix of assets (i.e., Aerial, Buried, Underground and In-Building, where applicable) within the Feeder, Distribution and Drop fibre categories, for each historical year in question.

    1. The average length (in metre) for each construction mix asset within the Feeder, Distribution and Drop fibre categories.
    2. The % allocation by construction mix assets within the Feeder, Distribution and Drop fibre categories based on locations built in year.
    3. The capital expenditure for each construction mix asset within the Feeder, Distribution and Drop fibre categories.
    4. The number of locations built in-year.
    5. The number of locations built to-date.

  2. Refer to Telecom Order 2024-261, where the Commission applied a 50% utilization factor for the distribution and feeder fibre penetration rate across TELUS’s territory in Alberta and British Columbia and noted that similar adjustments were not made for other companies since the record had not yet been developed and that the Commission will ensure consistency across companies when setting final rates.

    Provide responses to the following questions:

    1. Provide your view on the appropriateness of applying a 50% penetration rate, reflecting the assumption that, in an ideal competitive market, two facilities-based competitors have a 50% chance of gaining retail or wholesale subscribers.  
    2. Provide the associated revised proposed rates and cost information within the company cost study that incorporates a penetration rate of 50%.

Bell Canada, Bell Aliant, and Bell MTS

  1. For the following questions, refer to the files:

    • “PROPOSED - Bell Aliant TN 569C - ATT 2 - APP 2 - FTTP SC with Visit_ABR” (“Bell Aliant Installation Charge Model with Visit”)
    • “PROPOSED - Bell MTS TN 852C - ATT 2 - APP 2 - FTTP SC with Visit_ABR” (“Bell MTS Installation Charge Model with Visit”)
    • “13 May 2024 - 240611-Bell Canada(CRTC)13May24-7 TN 7664A - ATT 2 - APP 2 _ABR” (“Bell Canada Installation Charge Model with Visit”)

    Refer to the tasks, “INWARD SERV PROV_COORD AND TESTING BELL (years 1-5)” and “INWARD SERV PROV_COORD AND TESTING CONTRACTOR (years 1-5)” located in the tab, “Table 6a – Expenses”, rows 37 and 38, column C in the “Bell Aliant Installation Charge Model with Visit” and rows 41 and 42, column C in the “Bell MTS Installation Charge Model with Visit”. Further, refer to the task “INWARD SERV PROV_COORD AND TESTING BTS” located in the tab, “Table 6a – Expenses”, row 47, column C in the “Bell Canada Installation Charge Model with Visit”.

    Explain, with supporting rationale, why the touch times required to complete the same tasks differ across Bell Canada, Bell Aliant, and Bell MTS.

Bell Aliant

  1. Refer to paragraph 52 in “Bell Canada Report On The Economic Evaluation For The Introduction Of Gateway Access Service (GAS) - Fibre To The Premises (FTTP) Access Atlantic Canada Serving Area, 15 March 2024”, where it states:

    “The capital increase factors (CIFs), expense increase factors (EIFs), and the Commission-approved productivity improvement factor (PIF) were used to reflect cost increases and productivity changes within the study period, and in certain cases, to restate costs from their respective vintage to 2024 dollars.”

    Further, refer to Bell Aliant’s GAS-FTTP Access cost model, filename “FTTP Access_CONF_MasterFile GAS FTTP MRC ATL.XLS”, worksheet name “Fibre Capital Details”, where the annual financials by asset class in FTTP Distribution and Feeder Networks were restated to 2024 dollars.

    1. Explain in detail, with supporting rationale, why only capital increase factors, and not productivity improvement factors (PIFs), were used in restating the annual financials to 2024 dollars.
    2. Provide a revised cost model to reflect the inclusion of the PIF in the annual financials.

  2. Refer to paragraph 111 in “Bell Canada Report On The Economic Evaluation For The Introduction Of Gateway Access Service (GAS) - Fibre To The Premises (FTTP) Access Atlantic Canada Serving Area, 15 March 2024” where it states:

    “Maintenance consists of costs associated with ongoing maintenance and repair and service assurance activities.  The maintenance and repair expenses were calculated using M&R factors whereas the service assurance expenses were developed based on explicit time estimates and labour unit costs."

    Further, refer to Bell Aliant’s GAS-FTTP Access cost model, filename “FTTP Access_CONF_MasterFile GAS FTTP MRC ATL.XLS”, worksheets named “Expense Details (year 1-3)” and “Expense Details (year 4-5)”.

    1. Provide a completed table for each major expense item in “Service Assurance”, specifically “Dispatch for repair”, “Out order processing “, “Handling of trouble calls”, “Handling of trouble calls, subject matter expert”, “Repair - Bell Technician”, “Repair - Contractor Technician” and “Review repair trouble ticket for billing”, with the following information:

      1. Identify the sub-activity/sub-activities
      2. Provide a breakdown of each sub-activity into functions/tasks
      3. Provide time estimates (in minutes) for each function/task
      4. Identify any circumstances that could lead to significant deviation from standard timeframes, the anticipated occurrence rate of such circumstances and the average impact of such occurrences on applicable timeframes
      5. Identify efficiencies from initiatives to mechanize, integrate, eliminate and/or reduce the touch time of each function/task and the impact of such efficiencies on relevant time estimates and occurrence rates
      6. Provide the "% Occurrence Rate" for each function/task with supporting rationale
      7. Provide a process flowchart which depicts the sequence of functions/tasks described in a) above. The flowchart should also depict the functions/tasks that are done in parallel.
    2. For each of the major expense items “Handling of trouble calls”, “Handling of trouble calls, subject matter expert” and “Review repair trouble ticket for billing” in the worksheet named “Expense Details (year 1-3)”, explain in detail, with supporting rationale, why the occurrence rate is ##.
  3. For each service charge proposed when a site visit is required and when a site visit is not required, explain the criteria, with supporting rationale, assumptions, and related supporting documentation, that is used by the company to determine if and when a site visit is required.

  4. For the following questions, refer to the file:

    • “PROPOSED - Bell Aliant TN 569C - ATT 2 - APP 2 - FTTP SC with Visit_ABR” (“Bell Aliant Installation Charge Model with Visit”)

    1. Refer to tab “Table 6a – Expenses” of the “Bell Aliant Installation Charge Model with Visit” for the following items:

      1. Row 37, column C, “INWARD SERV PROV_NO ACCESS BELL (years 1-5)”
      2. Row 39, column C, “INWARD SERV PROV_REMOTE WORK BELL (years 1-5)”
      3. Row 41, column C, “INWARD SERV PROV_TRAVEL BELL (years 1-5)”
      4. Row 43, column C, “INWARD SERV PROV_COORD AND TESTING BELL (years 1-5)”
      5. Row 45, column C, “INWARD SERV PROV_CPE INSTALL BELL (years 1-5)”

      An occurrence rate of the resource and an occurrence of the task is typically provided. While the resource-specific occurrence rate of 80% for each of the above resources has been provided, provide the task-specific occurrence rate for each of the above tasks, with supporting rationale.

    2. Refer to tab “Table 6a – Expenses” of the “Bell Aliant Installation Charge Model with Visit” for the following items:

      1. Row 38, column C, “INWARD SERV PROV_NO ACCESS CONTRACTOR (years 1-5)”
      2. Row 40, column C, “INWARD SERV PROV_REMOTE WORK CONTRACTOR (years 1-5)”
      3. Row 42, column C, “INWARD SERV PROV_TRAVEL CONTRACTOR (years 1-5)”
      4. Row 44, column C, “INWARD SERV PROV_COORD AND TESTING CONTRACTOR (years 1-5)”
      5. Row 46, column C, “INWARD SERV PROV_CPE INSTALL CONTRACTOR (years 1-5)”

      An occurrence rate of the resource and an occurrence rate of the task is typically provided. While the resource-specific occurrence rate of 20% for each of the above resources has been provided, provide the task-specific occurrence rate for each of the above tasks, with supporting rationale.

    3. Recalculate the unit costs, including the occurrence rate of the resources and the occurrence rate for the tasks, for each of the activities identified in question 7) a) and question 7) b).

  5. For the following question, refer to Section B1 in the tab, “Table 6a – Expenses” within the “Bell Aliant Installation Charge Model with Visit”:

    1. In column I (“Time Estimate”), rows 30 to 46, all activities are assigned a value of 0.33 hours. Provide supporting documentation and sources to support these time estimates.  If they are in error, restate the correct time estimates for each activity.
  6. Provide an updated cost study and the associated revised proposed rates and cost information resulting from the responses to question 7) a), question 7) b), question 7) c), and question 8) a). Further, highlight the adjustments made in the cost study.

  7. Refer to Bell Aliant’s proposed rates referenced in Item 642 of its proposed tariff pages in the file “PROPOSED - WHOLESALE - Bell Aliant TN 569D - Tariff Pages” for the CBB Service Charges per IP-AHSSPI for:

    • 1000 Mbps
    • 10GE
    • 100GE
    1. Provide all supporting rationale, assumptions, calculations, and related supporting documentation that supports these proposed rates.

  8. Refer to Bell Aliant’s proposed rates referenced in Item 642 of its proposed tariff pages in the file “PROPOSED - WHOLESALE - Bell Aliant TN 569D - Tariff Pages” for the CBB Service Charges per order for:

    • 1000 Mbps
    • 10GE
    • 100GE
    1. Provide all supporting rationale, assumptions, calculations, and related supporting documentation that supports these proposed rates.

  9. Refer to Items 626.3 and 642.4 within Bell Aliant’s General Tariff 214916 in the file, “PROPOSED - Bell Aliant TN 569 - Tariff Pages”, wherein charges applicable to IP AHSSPI are referenced.

    1. Provide the forecasted average number of IP-AHSSPIs estimated to be requested by ISPs per order for each year of the cost study with supporting rationale, assumptions, and related supporting documentation.

Bell Canada

  1. Refer to paragraph 79 in “Bell Canada Report On The Economic Evaluation For The Introduction Of Gateway Access Service (GAS) -  Fibre To The Premises (FTTP) Access Ontario And Quebec, 31 May 2023, Revised 9 August 2023”, where it states:

    “The capital increase factors (CIFs), expense increase factors (EIFs), and the Commission-approved productivity improvement factor (PIF) were used to reflect cost increases and productivity changes within the study period, and in certain cases, to restate costs from their respective vintage to 2024 dollars.”

    Further, refer to Bell Canada’s GAS-FTTP Access cost model, filename “GAS-FTTP Access - E-Model - REV_CONF_MasterFile G.XLS”, worksheet name “Fibre Capital Details”, where the annual financials by asset class in FTTP Distribution and Feeder Networks were restated to 2024 dollars

    1. Explain in detail, with supporting rationale, why only capital increase factors, and not productivity improvement factors (PIFs), were used in restating the annual financials to 2024 dollars
    2. Provide a revised cost model to reflect the inclusion of the PIF in the annual financials.
  2. For each service charge proposed when a site visit is required and when a site visit is not required, explain the criteria, with supporting rationale, assumptions, and related supporting documentation, that is used by the company to determine if and when a site visit is required. For Bell Canada, since the temporary service was introduced in Telecom Decision CRTC 2023-358, provide the breakdown, by month, of site visits vs non-site visits in Bell Canada’s operating territory.

  3. For the following questions, refer to item 5460.4(d) in the file, “PROPOSED – WHOLESALE - Bell Canada TN 7664C – Tariff Pages.docx”, wherein it states: “[for] charges for Gateway Mapping Administration Fee, see Item 5410.4.(d) and (f)”.

    Further, refer to item 5410.4.(d) within Bell Canada’s General Tariff 6716Footnote 4, wherein it states that “Gateway Mapping Administration Fees will not apply to customers migrating an AHSSPI from the Company's ATM network to its IP network.”

    1. Clarify, with supporting rationale, how the Gateway Mapping Administration Fee is applicable to the FTTP service.

  4. Refer to the item 5410.4.(f) within Bell Canada’s General Tariff 6716 in the file, “PROPOSED - Bell Canada TN 7664 - Tariff Pages”, wherein charges applicable to legacy and internet protocol AHSSPI are provided.

    1. Provide the forecasted average number of AHSSPIs estimated to be requested by ISPs per order for each year of the cost study, with supporting rationale, assumptions, and related supporting documentation.

Bell MTS

  1. Refer to paragraphs 52 in “Bell Canada Report On The Economic Evaluation For The Introduction Of Gateway Access Service (GAS) - Fibre To The Premises (FTTP) Access Manitoba Serving Area, 15 March 2024”, where it states:

    “The capital increase factors (CIFs), expense increase factors (EIFs), and the Commission-approved productivity improvement factor (PIF) were used to reflect cost increases and productivity changes within the study period, and in certain cases, to restate costs from their respective vintage to 2024 dollars.”

    Further, refer to Bell MTS’ GAS-FTTP Access cost model, filename “FTTP Access_CONF_MasterFile GAS FTTP MRC MB.XLS”, worksheet name “Fibre Capital Details”, where the annual financials by asset class in FTTP Distribution and Feeder Networks were restated to 2024 dollars.

    1. Explain in detail, with supporting rationale, why only capital increase factors, and not productivity improvement factors (PIFs), were used in restating the annual financials to 2024 dollars.
    2. Provide a revised cost model to reflect the inclusion of the PIF in the annual financials.

  2. Refer to paragraph 113 in “Bell Canada Report On The Economic Evaluation For The Introduction Of Gateway Access Service (GAS) - Fibre To The Premises (FTTP) Access Manitoba Serving Area, 15 March 2024”, where it states:

    “Maintenance consists of costs associated with ongoing maintenance and repair and service assurance activities.  The maintenance and repair expenses were calculated using M&R factors whereas the service assurance expenses were developed based on explicit time estimates and labour unit costs."

    Further, refer to Bell MTS’ GAS-FTTP Access cost model, filename “FTTP Access_CONF_MasterFile GAS FTTP MRC MB.XLS”, worksheets named “Expense Details (year 1-3)” and “Expense Details (year 4-5)”.

    1. Provide a completed table for each major expense item in “Service Assurance”, specifically “Dispatch for repair”, “Out order processing”, “Call centre handling of repair calls”, “Escalation to test centre”, “Handling of trouble calls, subject matter expert”, “Handling of repair trouble ticket “, “Repair - Bell Technician”, “Repair - Contractor Technician” and “Review repair trouble ticket for billing”, with the following information:

      1. Identify the sub-activity/sub-activities
      2. Provide a breakdown of each sub-activity into functions/tasks
      3. Provide time estimates (in minutes) for each function/task
      4. Identify any circumstances that could lead to significant deviation from standard timeframes, the anticipated occurrence rate of such circumstances and the average impact of such occurrences on applicable timeframes
      5. Identify efficiencies from initiatives to mechanize, integrate, eliminate and/or reduce the touch time of each function/task and the impact of such efficiencies on relevant time estimates and occurrence rates
      6. Provide the "% Occurrence Rate" for each function/task with supporting rationale
      7. Provide a process flowchart which depicts the sequence of functions/tasks described in a) above. The flowchart should also depict the functions/tasks that are done in parallel.
  3. For each service charge proposed when a site visit is required and when a site visit is not required, explain the criteria, with supporting rationale, assumptions, and related supporting documentation, that is used by the company to determine if and when a site visit is required.

  4. For the following questions, refer to the file:

    • “PROPOSED - Bell MTS TN 852C - ATT 2 - APP 2 - FTTP SC with Visit_ABR” (“Bell MTS Installation Charge Model with Visit”)

    1. Refer to tab “Table 6a – Expenses” of the “Bell MTS Installation Charge Model with Visit” for the following items:

      1. Row 35, column C, “INWARD SERV PROV_NO ACCESS BELL (years 1-5)”;
      2. Row 37, column C, “INWARD SERV PROV_REMOTE WORK BELL (years 1-5)”;
      3. Row 39, column C, “INWARD SERV PROV_TRAVEL BELL (years 1-5)”;
      4. Row 41, column C, “INWARD SERV PROV_COORD AND TESTING BELL (years 1-5)”;
      5. Row 43, column C, “INWARD SERV PROV_CPE INSTALL BELL (years 1-5)”.

      An occurrence rate of the resource and an occurrence rate of the task is typically provided. While the resource-specific occurrence rate of 80% for each of the above resources has been provided, provide the task-specific occurrence rate for each of the above tasks, with supporting rationale.

    2. Refer to tab “Table 6a – Expenses” of the “Bell MTS Installation Charge Model with Visit” for the following items:

      1. Row 36, column C, “INWARD SERV PROV_NO ACCESS CONTRACTOR (years 1-5)”
      2. Row 38, column C, “INWARD SERV PROV_REMOTE WORK CONTRACTOR (years 1-5)”
      3. Row 40, column C, “INWARD SERV PROV_TRAVEL CONTRACTOR (years 1-5)”
      4. Row 42, column C, “INWARD SERV PROV_COORD AND TESTING CONTRACTOR (years 1-5)”
      5. Row 44, column C, “INWARD SERV PROV_CPE INSTALL CONTRACTOR (years 1-5)”:

      An occurrence rate of the resource and an occurrence of the task is typically provided. While the resource-specific occurrence rate of 20% for each of the above resources has been provided, provide the task-specific occurrence rate for each of the above tasks, with supporting rationale.

    3. Recalculate the unit costs, including the occurrence rate of the resources and the occurrence rate for the tasks, for each of the activities identified in question 20) a) and question 20) b).

  5. For the following question, refer to the tab “Table 6a – Expenses” within the “Bell MTS Installation Charge Model with Visit”:

    1. In column I (“Time Estimate”), rows 29 to 44, all activities are assigned a value of 0.86 hours. Provide supporting documentation and sources to support these time estimates.  If they are in error, restate the correct time estimates for each activity.
  6. Provide an updated cost study and the associated revised proposed rates and cost information resulting from the responses to question 20) a), question 20) b), question 20) c), and question 21) a). Further, highlight the adjustments made in the cost study.

  7. Refer to Item 5840.4.C in the file “APP - PROPOSED - Bell MTS TN 852C - Tariff Pages”, wherein it states, “[for] AHSSPI Charges see 5830.6”. Further, refer to Item 5830.6, wherein the monthly rate and service charge for the “10 GE or 100 GE Service Provider Interface (V-AHSSPI)” are provided.

    1. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation, how Bell MTS established its proposed “10 GE or 100 GE V-AHSSPI” monthly rate and service charge.
    2. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation why there is a difference between the rates for the “Up to 1 Gbps V-AHSSPI” service charge, and the “10 GE or 100 GE V-AHSSPI” service charge.

  8. Refer to Item 5830.6 in the file “APP - PROPOSED - Bell MTS TN 852C - Tariff Pages”. In respect to the following subsequent service charges for existing V-AHSSPI:

    • Per Order
    • Per Interface
    1. Provide the forecasted average number of V-AHSSPIs estimated to be requested by ISPs per order for each year of the cost study with supporting rationale, assumptions, and related supporting documentation.

TELUS

  1. Refer to the intervention by Competitive Network Operators of Canada (CNOC)Footnote 5, paragraphs 171-172 where it stated:

    “TELUS proposes rates up to 1.5 Gbps in Alberta, British Columbia and Quebec. And yet, TELUS offers “Internet OPTIK Giga 2.5 Gbps” to retail end-users in Quebec and “PureFibre X Internet 3G” (3 Gbps) to retail end-users in Alberta and British Columbia. TELUS does not explain why these services were excluded from the Tariff Applications.”

    “TELUS’ failure to include these higher speed services is contrary to the speed matching requirements. The omission is also contrary to the Commission’s clear directions with respect to the filing of Tariff Applications for aggregated wholesale HSA services over FTTP facilities.”

    Further, refer to Bell Canada’s Tariff Notice (TN) 7664AFootnote 6, where it filed cost studies for XGS-PON (for speeds greater than 1.5 Gbps) service, and to Telecom Order 2024-261, where the Commission set interim approved rates for aggregated wholesale fibre-to-the-premises high-speed access (HSA) services effective 25 October 2024.

    Accordingly, file aggregated wholesale HSA tariffs and associated Phase II cost studies with supporting rationale, for all omitted service speeds on a wholesale basis that are currently offered at the retail level over FTTP access facilities, in both its Quebec and Alberta / British Columbia serving territories.

    Along with its submission, TELUS is to provide a description and a network diagram that explains how FTTP access facilities are integrated into the aggregated wholesale HSA services. The diagram and description must clearly describe the connection path for an access over FTTP facilities, starting at the end-customer premises demarcation point and ending at the point of interconnection (POI), and the diagram must identify each network element in the connection path. Further, TELUS is to describe the equipment that a competitor is required to provide at the customer premises to support its Internet service over FTTP access facilities, specifying what company equipment it connects to.

    The filing of information, including in the associated cost studies, should be consistent with the confidentiality guidelines set out in Telecom Regulatory Policy 2012-592.

    Finally, TELUS is reminded to provide an electronic copy (i.e., Excel spreadsheets) of the cost model which shall include all formulae and shall not include hard coded numbers that are not supported by either an internal/external reference, explanation or other supporting rationale. The populated model shall include all the associated linked spreadsheet files that contain supporting data used to develop the costs. Additionally, a description of the input data variables, the vintage of the input data used, explanations of all modelling assumptions with supporting rationale, and any other pertinent costing information and details shall be provided along with the associated Study Report.

  2. Refer to the RFI response in the letterFootnote 7 (i.e., Attachment 1, worksheet name “Table 6b – Capital”) where TELUS provided the configuration and capital cost breakdown (2016 vintage) of the 7750 router edge device. Further, refer to TELUS’ 2023 FTTP access (filename: “Tariff Notice - Access_Support_10G RE 7750 Port.XLS”) and CBB (filename: “Tariff Notice - CBB_Support_10G RE 7750 Port Cost per Mbps.XLS”) models for the “10 RE 7750 Port” equipment with 2023 vintage cost data.

    1. Using 2016 vintage material cost data and the cost increase factor  / productivity improvement factor (PIF) for asset class E10 as calculated in your file named “CIF usage-sensitive equipment_WHSA”, explain in detail, with supporting rationale, why the corresponding 2023 vintage material costs are either the same or do not reflect resulting costs after applying the cost increase factors and PIF over the period from 2016 to 2023.

    2. With regards to the material cost component “##”:

      1. Explain in detail, with supporting rationale, why this component was fully costed on a capacity basis in each of the 2023 access and capacity-based billing (CBB) cost models considering that it is a common material cost component for both access and network line connections.
      2. Provide your comments in detail, with supporting rationale, on the appropriateness of allocating this cost component to all of either access or CBB, or in part to each of access and CBB.
      3. Provide revised access and CBB cost models, where applicable, to reflect your response to question 26) b) ii) above.

    3. With regards to the use of an ## in the 2023 CBB cost model:

      1. Explain in detail, with supporting rationale, why a “straight average” was employed to create the average unit cost as opposed to a “weighted average”Footnote 8 based on future network deployment.
      2. Provide an occurrence rate for each “##” identified (total equals 100%) based on network deployment up to and including the end of 2024. Further, provide a detailed explanation, with supporting data and rationale, on how the occurrence rate was derived

  3. Refer to TELUS’ TN 583, item 236.2 where it states:

    “Optical Network Terminal (ONT)” is a powered device that transports PPPoE data traffic to and from the End-user’s Premises through the Company’s fibre network. The ONT serves as the Company’s point of demarcation at the End-user’s Premises. The End-user must supply power to the ONT.”

    1. Provide your comments in detail, with supporting rationale, on the requirement to include the “powered device” in the provisioning of wholesale FTTP access service.
    2. Provide your comment on whether market alternative(s) exist in place of the “powered device”.
    3. Provide your comments in detail, with supporting rationale, on the appropriateness of allowing a competitor the option to supply its own alternative.

  4. With regards to TELUS’ FTTP access network rollout in Alberta and British Columbia, refer to the following documents:

    Telecom Notice of Consultation CRTC 2023-56, Review of the wholesale high-speed access service framework, Intervention of TELUS Interim Aggregated Wholesale Access to Fibre to the Premises Networks, April 24, 2023, paragraphs 99-100, where it stated:

    “…TELUS faces a requirement in many areas in the West to run its network underground rather than through above ground support structures. This requires placement of underground conduit before fibre can be pulled through it. In many cases conduit does not exist and must be installed. The requirement to put FTTP facilities underground stems from differences in geographical features of the landscape and the configurations required by provincial and/or municipal authorities.

    As a result of these requirements, ## ”

    TELUS Communications Inc. Report On The Economic Evaluation For Aggregated Wholesale High-Speed Access (HSA) Service, Introduction Of Fibre To The Premises (FTTP) Access Service – Up To 1.5 GBPS, May 31, 2023, paragraph 26, where it stated:

    “In the key cost category of outside plant, Alberta’s FTTP access network is dominated by buried infrastructure, whereas the construction technique in British Columbia is primarily aerial or underground via existing conduit.”

    Telecom Notice of Consultation CRTC 2023-56, Notice of hearing – Review of the wholesale high-speed access service framework TARIFF NOTICE NO. 583/657 Reply of TELUS, July 20, 2023, paragraph 33, where it stated:

    “TELUS further explained that in Alberta brownfield areas, as well as newer subdivisions, fibre cables are predominately placed underground, which is significantly more expensive than aerial installation.”

    TELUS’ “Response to Request For Information Follow up to TNC 2023-56 TELUS(CRTC)13May24-8”, where it stated:

    “In all parts of TELUS’ cost study, fibre below ground level is within existing or new conduit and should therefore have been labeled ‘underground’ rather than ‘buried’.”

    Further, refer to the “Response to Request For Information Follow up to TNC 2023-56 TELUS(CRTC)28June24-1”, where the total FTTP distribution/feeder capital expenditure (capex), specifically for asset class A32 (Cable - Underground fibre), inclusive of all material and labour, and the number locations built in-year were provided.

    1. Of the total in-service base of fibre access locations built, provide the actual number of locations built (2024 year-to-date), that are aerial, buried (without conduit) and underground (with conduit) by province (i.e., British Columbia and Alberta) by completing the Excel worksheet in Attachment 2.
    2. Provide your comments in detail, with supporting rationale, on the appropriateness of applying a forecasted/future fibre access construction mix when developing the incremental unit cost by fibre access asset class per location built given the Commission determination in Telecom Regulatory Policy 2024-180 that Incumbent Local Exchange Carriers (ILEC), including TELUS, are granted a time-limited exemption to the requirement to offer aggregated FTTP services for any premises where the ILEC begins offering retail Internet services over FTTP for the first time on or after the date of the regulatory policy, to be in place until 12 August 2029.

  5. For the following questions, refer to the two corresponding TELUS confidential files, by province, named “Tariff Notice – Installation Collator – FTTP Installation”, submitted on 31 May 2023 for Alberta and British Columbia (“TN 583 Collator”), and for Quebec (“TN 657 Collator.”).

    1. Refer to both “TN 583 Collator” and “TN 657 Collator”. In tab “DmdRev”, column B, row 30, where it states, ##:

      1. Provide the company’s interpretation of “churn”. 
      2. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation, how TELUS established its churn rate.
    2. Provide updated cost studies, the associated revised proposed rates, cost information, a revised “TN 583 Collator” file, and a revised “TN 657 Collator” file that includes the supporting rationale, assumptions, calculations, and related supporting documentation related to the service charge when a visit is required and when a visit is not required. Further, highlight the adjustments made in the cost study.
  6. For each service charge proposed when a site visit is required and when a site visit is not required in TELUS Quebec, Alberta and British Columbia, explain the criteria, with supporting rationale, assumptions, and related supporting documentation, that is used by the company to determine if and when a site visit is required. Since the temporary service was introduced in Telecom Decision CRTC 2023-358, provide the breakdown, by month, of site visits vs non-site visits in TELUS Quebec’s operating territory.

SaskTel

  1. Refer to the document titled, “SaskTel_CRTC_16_Att3_CONF_rev.XLS”, dated 28 June 2024, worksheet titled, “Table 6b – Capital”, row 34, column B, titled, “Customer Premise Equipment – IP”, where the company has provided the unit cost based on supplied price for the asset class X194.

    Further refer to the document titled, “SaskTel_CRTC_21_Att1_ABR.XLS”, dated 13 May 2024, row 10, columns A-F, where the company has identified the customer service technician as the resource that installs and test the ONT.

    1. Provide a completed Table 6b, including Section A1, consistent with the detailed cost information requirements outlined in the Commission staff letter dated 13 September 2013Footnote 9,  Attachment, “Detailed Cost Information Requirements”.
    2. Provide the capital unit cost, and the associated incremental cost driver demand forecast used to estimate the capital cash flow along with the associated PWAC and $ per billing unit.
    3. Submit an abridged version of Table 6b, Section A1 to be put on the public record consistent with the determinations in Telecom Regulatory Policy 2012-592.
    4. Explain how the installation costs for the “Customer Premise Equipment – IP” is included in the economic study, providing all calculations and supporting documentation, and further comment on whether it is included in the proposed ongoing monthly cost or in the service charges.
    5. If the company arrives at either a different capital unit cost or different cost inclusion method, based on the responses above, than proposed in the 28 June 2024 cost study, provide the associated revised proposed rates and cost information within SaskTel’s cost study that incorporates the response from question 31) b) above, including revisions of Table 6b, and an abridged version of Table 6bA1.

  2. Refer to the cost model, “SaskTel_7 IVA Refile Wholesale FTTP Access - July Cost Model v1CONF”, dated 28 June 2024, worksheet tab titled “Defaults”, row 127, titled, “Customer Premise Equipment – IP”, asset class X194, and columns D and E, titled, “CRTC Cost Increase Factors”, where the company has provided the cost increase factor (CIF) for asset class X194.

    Further refer to SaskTel’s Attachment to Appendix V of its Phase II Costing Manual submitted on 10 February 2021, worksheet titled, “PIFs EIFs CIFs”, row 61, columns B and C, where SaskTel has provided the CIF for asset class X194 as 0% for 2020/21 and 2021/22, and 10% for years 2022/23 onwards, with a vintage year of source data of 2013.

    Further refer to Telecom Decision CRTC 2016-117Footnote 10, paragraph 52, where it states:

    “With respect to the proposal to use an asset-specific CIFFootnote 11 instead of a service-specific CIFFootnote 12, asset-specific CIFs are based, in part, on the functions of an asset beyond those that may pertain to the wholesale HSA service. To determine wholesale HSA service rates, the cost reduction factor should be specific to the equipment used to provide the wholesale HSA service. As a result, and consistent with the approach adopted in the 2011 Regulatory Policies, the continued use of a service-specific capital unit cost factor remains appropriate for all wholesale HSA service providers.”
    1. Comment on whether the proposed CIF of 10% is specific to the customer premise equipment used to provide the wholesale HSA FTTP service or is developed from corporate data for customer premise equipment asset class such that the proposed CIF is based, in part, on assets beyond those which may pertain to the wholesale HSA FTTP service.
    2. Provide 2018-2022 historical cost data that pertains only to the “Customer Premise Equipment – IP” for the wholesale HSA FTTP service, i.e. service-specific CIF.
    3. Calculate and provide, in Excel format, with all necessary formulas and references, a service-specific CIF for “Customer Premise Equipment – IP” based on the 2018-2022 historical cost data provided in 32) b) above.
    4. If the service-specific 2018-2022 historical cost data from 32) c) above results in a different CIF than the one proposed in the 28 June 2024 cost model, provide the associated revised proposed rates and cost information within SaskTel’s cost study that incorporates the response from question 32) c) above.

  3. Refer to Telecom Regulatory Policy (TRP) 2024-180Footnote 13, paragraph 57, where it states:

    “The Commission grants the ILECs a time-limited exemption to the requirement to offer aggregated FTTP services. This exemption applies to any premises where the ILEC begins offering retail Internet services over FTTP for the first time on or after the date of this regulatory policy. This exemption will remain in place until 12 August 2029, after which the ILECs must begin offering aggregated FTTP services to all previously exempted premises.”

    Further refer to the company submission titled, “Cost Study for Aggregated Wholesale HSA Service”, dated 1 November 2023, paragraph 23, where the company submitted the following:

    “The HSA over FTTP Access cost was determined using the latest internal cost model to support business case decisions as part of SaskTel’s FTTP deployment. Cash flows relating to communities served at the beginning of the cost study period were developed using the internal model with current costs. The costs of approved future deployments were developed using the same tool. Given the uncertainty of when these locations will be served, it was assumed that all cashflows for these communities will occur at the beginning of year 3.”

    Further refer to the cost model, “SaskTel_7 IVA Refile Wholesale FTTP Access - July Cost Model v1CONF”, dated 28 June 2024, worksheet tab titled, “Input”, where the company provided the cashflows for approved future deployments, assuming they will occur at beginning of year 3 of the cost study, i.e. 2025.

    Further refer to the document, titled, “SaskTel_7 FTTC WC_17July_Att2_App1_IFC - July Cost Model v2 CONF.XLS”, dated 28 June 2024, worksheet tab titled “Output_All” where the capital expenditures are provided by asset class by Community.

    1. Provide an updated worksheet “Output_All” that includes only communities that have access to FTTP service as of 13 August 2024, consistent with the date of Telecom Regulatory Policy 2024-180.
    2. Provide the associated revised proposed rates and cost information within SaskTel’s cost study that incorporates the response from question 33) a) above.

  4. Refer to the document titled, “Cost Study for Aggregated Wholesale HSA Service”, dated 1 November 2023, Paragraph 23, where the company submitted the following:

    “The HSA over FTTP Access cost was determined using the latest internal cost model to support business case decisions as part of SaskTel’s FTTP deployment. Cash flows relating to communities served at the beginning of the cost study period were developed using the internal model with current costs.”

    Further refer to the cost model, “SaskTel_7 IVA Refile Wholesale FTTP Access - July Cost Model v1CONF”, dated 28 June 2024, worksheet tab titled, “Input”, where the company provided the cash flows relating to communities served at the beginning of the cost study period, i.e. 2023.

    Further refer to question 1.c. above, where the company is asked to provide the capital expenditure for each construction mix asset within the Feeder, Distribution and Drop fibre categories for historical years 2008-2024 and forecast year 2025.

    1. Provide retrospective cost increase factors (CIFs) and productivity improvement factors (PIFs) used to restate the historical annual capital cash flows to the first year of the study period, i.e. 2023.
    2. Demonstrate, in Excel format, with all necessary formulas and references, how the company has restated the historical cash flows to the first year of the study period, i.e. 2023.
    3. Confirm that the CIFs and PIFs used to restate the historical annual capital cash flows are the same as CIFs and PIFs in SaskTel’s Attachment to Appendix V of its Phase II Costing Manual submitted on 10 February 2021, worksheet titled, “PIFs EIFs CIFs”. If different CIF / PIF / EIF were used, comment, with supporting rationale, on why the company has used different CIFs and PIFs than the ones in its Phase II Costing Manual.
    4. If the company has used different CIFs and PIFs than the ones used in its Appendix V dated 10 February 2021, provide the associated revised proposed rates and cost information within SaskTel’s cost study that incorporates the CIFs and PIFs in SaskTel’s Attachment to Appendix V of its Phase II Costing Manual submitted on 10 February 2021.

  5. Provide (i) an updated cost model and (ii) the associated revised proposed rates and cost information that incorporates the responses to the above questions included in the requests for information, where applicable.

    1. Question 2) b);
    2. Question 31) b);
    3. Question 32) c);
    4. Question 33) a);
    5. Question 34) d).
  6. For each service charge proposed when a site visit is required and when a site visit is not required, explain the criteria, with supporting rationale, assumptions, and related supporting documentation, that is used by the company to determine if and when a site visit is required. Provide a 3-year forecast of site visits vs non-site visits with supporting rationale, assumptions, calculations, and related supporting documentation.

  7. Refer to the file, “SaskTel_Cost_Studies_TN378B_ ABR_231101_SaskTel_Cost Study_TN378B_App1_ ABR_rev”:

    1. Refer to Note 5 within the tab “Table 1”, where it states that the Domain Name and CBB Change Service Connection Charge and Subsequent Domain Name and CBB Change Service Connection Charge costs were estimated using a resource cost study. Provide the associated resource cost studies, including all supporting calculations, in Excel format, with all necessary formulas and references, demonstrating how these proposed rates were determined.

  8. Refer to the file, “13 May 2024 - SaskTel_CRTC_21_Att1_ABR.”

    1. Refer to the data provided for the access service charges for new installations contained within the tab “Access SCC”. In respect to the hours estimated for sales representatives when a field visit is required (row 7, column F) and when a field visit is not required (row 7, column I):

      1. Explain, with supporting rationale and assumptions and providing the sources of the information, how the time estimates for sales representatives were developed for the FTTP service when a field visit is required, and when a field visit is not required.

      2. Provide the equivalent employees and the touch time in hours for sales representatives related to each activity listed below when a field visit is required, and when a field visit is not required:

        • Receive order
        • Verify customer and address
        • Create service order
        • Create billing records
        • Book technician for service order
        • Complete and release service order
        • Communicate with HSSP for queries and confirmation.
      3. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation, why the total touch time reported for sales representatives have changed from the data reported in the tab “Access SCC” at row 11, column B within the file, “InfoSupp-AddInfo - SaskTel - 15 August 2023 - Supporting Documents for Wholesale FTTP_Access and Interface SCC”.
      4. Explain, with supporting rationale and assumptions, how the activities and touch times listed in question 38) a) ii) related to the FTTP service are similar and/or different than those related to the ADSL service.

    2. Refer to the data provided for the access service charges for new installations contained within the tab “Access SCC”. In respect to the hours estimated for senior clerical associates when a field visit is required (row 8, column F) and when a field visit is not required (row 8, column I):

      1. Explain, with supporting rationale and assumptions and providing the sources of the information, how the time estimates for senior clerical associates were developed for the FTTP service when a field visit is required, and when a field visit is not required.

      2. Provide the equivalent employees and the touch time in hours for senior clerical associates related to each activity listed below when a field visit is required, and when a field visit is not required:

        • Receive service order in one system
        • Transfer the service order in provisioning system with assignments of proper interface identifiers
      3. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation, why the total touch time reported for sales representatives have changed from the data reported in the tab “Access SCC” at row 12, column B within the file, “InfoSupp-AddInfo - SaskTel - 15 August 2023 - Supporting Documents for Wholesale FTTP_Access and Interface SCC”.
      4. Explain, with supporting rationale and assumptions, how the activities and touch times listed in question 38) b) ii) related to the FTTP service are similar and/or different than those related to the ADSL service.

    3. Refer to the data provided for the access service charges for new installations contained within the tab “Interface SCC”. In respect to the hours estimated for the sales associate (row 5, column F):

      1. Explain, with supporting rationale and assumptions and providing the sources of the information, how the time estimates for the sales associate were developed for the FTTP service.

      2. Provide the equivalent employees and the touch time in hours for the sales associate related to each activity listed below:

        • New customer setup
        • Communication with customer including quotes
        • Service design
        • Other setup queries
      3. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation, why the total touch time reported for sales representatives have changed from the data reported in the tab “Interface SCC” at row 10, column B within the file, “InfoSupp-AddInfo - SaskTel - 15 August 2023 - Supporting Documents for Wholesale FTTP_Access and Interface SCC”.
      4. Explain, with supporting rationale and assumptions, how the activities and touch times listed in question 38) c) ii) related to the FTTP service are similar and/or different than those related to the ADSL service.

    4. Refer to the data provided for the access service charges for new installations contained within the tab “Interface SCC”. In respect to the hours estimated for the engineering assistant (row 7, column F):

      1. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation, how the time estimates for the engineering assistant were developed for the FTTP service.

      2. Provide the equivalent employees and the touch time in hours for the engineering assistant related to each activity listed below:

        • Design circuit layout records
        • Create SAP Network activity for material requisition
        • Create work orders
      3. Explain, with supporting rationale, assumptions, calculations, and related supporting documentation, why the total touch time reported for sales representatives has changed from the data reported in the tab “Interface SCC” at row 9, column B within the file, “InfoSupp-AddInfo - SaskTel - 15 August 2023 - Supporting Documents for Wholesale FTTP_Access and Interface SCC”.
      4. Explain, with supporting rationale and assumptions, how the activities and touch times listed in question 38) d) ii) related to the FTTP service are similar and/or different than those related to the ADSL service.

  9. For the following questions, refer to the files:

    • “SaskTel_TN378_378A_Reply_Att_NC23-56_ABR.xlsx” (“SaskTel Service Charge Model”)
    • “Sasktel - 230531_SaskTel_Cost Study_TN378A_Att2_ABR”, filed on 31 May 2023 (“SaskTel Cost Study Report”)

    1. The Commission, under Telecom Order CRTC 2024-261, shifted costs captured by SaskTel’s HSA Enablement Fees to a separate HSA Access Fee spread over a 10-year period. The interim rate set by the Commission for the FTTP HSA Enablement Fee (per competitor HSA access connection per month) is $5.65, in effect for 10 years.

      1. Comment, with supporting rationale, assumptions, calculations, and related supporting documentation, whether SaskTel agrees that this approach allows SaskTel to recover its costs, while not posing an undue barrier to entry or over-recovery of costs if more companies enter the market than anticipated, as noted in Footnote 4 of Telecom Order CRTC 2024-261.
      2. If SaskTel disagrees with the approach implemented by the Commission, provide an alternate service charge structure, along with the supporting costing model, cost study, supporting rationale, assumptions, calculations, and related supporting documentation, that does not pose a barrier to entry to competitors.

    2. Refer to the “Enablement Fee” tab, rows 9 to 11 of the “SaskTel Service Charge Model”.

      1. Confirm whether the total number of access nodes to be modified is equal to the total number of access nodes in SaskTel’s operating territory.
      2. If the total number of access nodes to be modified is not equal to the total number of access nodes in SaskTel’s operating territory, state the percentage of DSLAMs and OLTs that SaskTel will configure for the wholesale aggregated HSA FTTP service.
      3. Explain how SaskTel determined the requisite number of DSLAMs and OLTs to be reconfigured.
      4. If other services will also benefit from the reconfiguration of the DSLAMs and OLTs, provide an estimate of the percentage of the costs related to the enablement fee that is causal to the wholesale aggregated HSA FTTP service.
      5. Provide a revised enablement fee and accompanying cost model that reflects an ongoing monthly service charge, assuming a 10-year amortization and leaving all other variables unchanged. Provide all supporting rationale, assumptions, calculations, and related supporting documentation.
    3. Provide an updated cost study and the associated revised proposed rates and cost information resulting from the responses to question 39) a) and question 39) b). Further, highlight the adjustments made in the cost study.

CNOC, TekSavvy and other ISPs

  1. Refer to TELUS’ TN 583, item 236.2 where it states:

    “Optical Network Terminal (ONT)” is a powered device that transports PPPoE data traffic to and from the End-user’s Premises through the Company’s fibre network. The ONT serves as the Company’s point of demarcation at the End-user’s Premises. The End-user must supply power to the ONT.”
    1. Provide your comments in detail, with supporting rationale, on the requirement to include the “powered device” in the provisioning of wholesale FTTP access service.
    2. Provide your comment on whether market alternative(s) exist in place of the “powered device”.
    3. Provide your comments in detail, with supporting rationale, on the appropriateness of allowing a competitor the option to supply its own alternative.
Date modified: